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Privacy Shield Notice

eevo (“we,” “us,” or “our”) complies with the requirements of EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Principles”).  We have certified that we adhere to the Principles with respect to personal information (as defined below) that is transferred from the European Union and its Member States, and the European Economic Area and Switzerland (“EU”) to the United States.  If there is any conflict between the terms of this Privacy Shield Notice and the Principles, the Principles shall govern.  eevo is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.

This Privacy Shield Notice applies to personal information within the scope of eevo’s Privacy Shield certification, which covers the following categories of information:

For the purposes of this Privacy Shield Notice, “personal information” means information that is about, or pertains to a specific individual and can be linked either directly or indirectly to that individual.  In addition, certain personal information covered by this Privacy Shield Notice may be subject to more specific privacy policies of eevo, which are also consistent with the requirements of the Principles, and in the case of any conflict between these policies and the Principles, the Principles will control.

Individual Notice and Choice

We collect and process personal information from certain individuals and for the purposes described in this Privacy Shield Notice.  Personal information covered by this Privacy Shield Notice is collected and processed only as permitted by the Principles.

Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Notice or the eevo Privacy Policy.

Disclosures and Accountability for Onward Transfers

Consistent with the Principles, we may transfer personal information to third parties, including transfers from one country to another.  We will only disclose an individual’s personal information to third parties under one of the following conditions:

Access

Individuals whose personal information is covered by this Privacy Shield Notice have the right to access the personal information that we maintain about them as specified in the Principles.  Individuals may contact us to correct, amend, or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated).  Requests for access, correction, amendment or deletion should be sent to privacy@eevo.com.

Security

eevo takes appropriate measures to protect personal information to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration and destruction.  These measures take into account the nature of the personal information and the risks involved in its processing, as well as standard practices in the industry for security and data protection.

Data Integrity and Purpose Limitation

We collect and process personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject.  eevo does not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized.  We take reasonable steps to ensure that the personal information we have is accurate, but if you wish to correct any personal data, contact us at privacy@eevo.com.

Enforcement

In compliance with the Principles, eevo commits to resolve complaints about our collection or use of your personal information.  Individuals with inquiries or complaints should first contact eevo at privacy@eevo.com.   eevo has a policy of responding to individuals within one month of an inquiry or complaint.  If an individual has an unresolved complaint or concern that is not addressed satisfactorily, that individual may contact our U.S. based third party dispute resolution provider (free of charge), JAMS.  Please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint.

You may have the option to elect binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances.  For further information, please see the Privacy Shield website.  To learn more about the Privacy Shield Framework, and to view eevo’s certification, please visit https://www.privacyshield.gov.

Modifications

eevo may update this Privacy Shield Notice at any time by publishing an updated version here.  We will not update this Privacy Shield Notice in contravention to the Principles so long as we remain certified to the Privacy Shield Framework.

Privacy Shield Notice Effective: June 1, 2018